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Home My WebLink About09-6048SMIGEL, ANDERSON & SACKS, LLP Susan E. Good, Esquire ID #93294 4431 North Front Street, 3rd Flr. Harrisburg, PA 17110-1778 (717) 234-2401 sgood@saslip.com Attorney for Plaintiff JOHN T. MAHONEY, PLAINTIFF V. DEBORAH K. MAHONEY, DEFENDANT IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA DOCKET NO. 0-11-6'6 tj j : CIVIL ACTION -DIVORCE NOTICE TO DEFEND AND CLAIM RIGHTS YOU HAVE BEEN SUED IN COURT. If you wish to defend against the claims set forth in the following pages, you must take prompt action. You are warned that if you fail to do so, the case may proceed without you and a decree of divorce or annulment may be entered against you for any other claim or relief requested in these papers by the Plaintiff. You may lose money or property or other rights important to you, including custody or visitation of your children. When the ground for the divorce is indignities or irretrievable breakdown of the marriage, you may request marriage counseling. A list of marriage counselors is available in the Office of the Prothonotary, Cumberland County Courthouse, Carlisle, Pennsylvania, 17013. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, LAWYER'S FEES OR EXPENSES BEFORE A DIVORCE OR ANNULMENT IS GRANTED, YOU MAY LOSE THE RIGHT TO CLAIM ANY OF THEM. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY BAR ASSOCIATION 32 SOUTH BEDFORD STREET CARLISLE, PA 17013 (717) 249-3166 AMERICANS WITH DISABILITIES ACT OF 1990 The Court of Common Pleas of Cumberland County is required by law to comply with the Americans with Disabilities Act of 1990. For information about accessible facilities and reasonable accommodations available to disabled individuals having business before the Court, please contact our office. All arrangements must be made at least 72 hours prior to any hearing of business before the Court. SMIGEL, ANDERSON & SACKS, LLP Susan E. Good ID #93295 4431 North Front Street, 3rd Flr. Harrisburg, PA 17110-1778 'C (717) 234-2401 sgoodAsasllp.com Attorney for Plaintiff JOHN T. MAHONEY, IN THE COURT OF COMMON PLEAS PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA V. NO. DEBORAH K. MAHONEY, DEFENDANT CIVIL ACTION - DIVORCE COMPLAINT UNDER SECTION 3301(c) OR 3301(d) OF THE DIVORCE CODE TO THE HONORABLE, THE JUDGES OF SAID COURT: AND NOW, comes Plaintiff, JOHN T. MAHONEY, by his attorneys, SMIGEL, ANDERSON & SACKS, and represents as follows: COUNTI DIVORCE UNDER SECTION 3301(c) OR 3301(d) OF THE DIVORCE CODE 1. Plaintiff is John T. Mahoney, who currently resides at 1400 Blackhorse Hill Road, Building 6, VAMC, Coatesville, Coatesville, Chester County, Pennsylvania and has resided there since on or about May of 2008. 2. Defendant is Deborah K. Mahoney, who currently resides at 1952A Fry Loop, Carlisle, Cumberland County, Pennsylvania, Pennsylvania and has been residing there since on or about November 2008. 3. Both Plaintiff and Defendant have been bona fide residents in the Commonwealth for at least six (6) months immediately previous to the filing of this Complaint. 4. The Plaintiff and Defendant were married on June 3, 1989, at Newville, Pennsylvania. 5. There have been no prior actions of divorce or for annulment between the parties. 6. The marriage is irretrievably broken. 7. Plaintiff has been advised that counseling is available and that Plaintiff may have the right to request that the Court require the parties to participate in counseling. 8. Plaintiff avers that there are no children of the parties under the age of 18. WHEREFORE, Plaintiff requests the court to enter a decree of divorce. SMIGEL, ANDERSON & SACKS, LLP Date: August b4, 2009 By: e-larr-A Susan E. Good, Esquire ' I.D. #93295 4431 North Front Street, 3" Fl. Harrisburg, PA 17110-1778 (717) 234-2401 Attorney for Plaintiff VERIFICATION I, John T. Mahoney, verify that the statements contained in the foregoing pleading are true and correct to the best of my knowledge, information and belief. I understand that false statements therein are made subject to the penalties of 18 Pa.C.S. §4904, relating to unsworn falsification to authorities Date: 1ZLIO J n T. ahoney eft _,_ _ F- of TF! .14RY L"LlM9 S P -J ('' i J J r SMIGEL, ANDERSON & SACKS, LLP Susan E. Good, Esquire ID #93294 4431 North Front Street, 3rd Flr. Harrisburg, PA 17110-1778 (717) 234-2401 sgood(Rsasllu.com Attorneys for Plaintiff JOHN T. MAHONEY, PLAINTIFF V. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA : DOCKET NO. 09-6048 : CIVIL ACTION -DIVORCE AFFIDAVIT OF SERVICE I, Susan E. Good, Esquire, attorney for Plaintiff in the above-captioned matter, do hereby DEBORAH K. MAHONEY, DEFENDANT certify that I served a true and correct copy of Plaintiff's Complaint Under Section 3301(c) or 3301(d) of the Divorce Code by delivering same by U.S. Certified Mail, return receipt requested, Article Number 7007 2560 0001 6044 5201, postage prepaid, on September 8, 2009, addressed as follows: Deborah K. Mahoney 1952A Fry Loop Carlisle, PA 17013 Defendant received said document on September 10, 2009, as evidenced by her signature on the certified mail return receipt card which is attached hereto. I verify that the statements in the foregoing Affidavit are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. §4904, relating to unsworn falsification to authorities. SMIGEL, ANDERSON & SACKS, LLP 1 Date: `/? g Stfsan E. Good, Esquire I.D. #- 93295 4431 North Front Street Harrisburg, PA 17110 (717) 234-2401 Attorney for Plaintiff A, If ., ¦ Compiete items 1, 2, and I Also complete 4 if Restrttb -D etyc is-desired. '> tWur name and address on the reverse so that we can return the card to you. ¦ Attach this card to the back of the malipiece, or on the front if space permits. 1. Article Addressed to: ?(f (? DOO.li l ?. Ct?ll3 1? 115 a A Look 1ee, VA t? 3 D Agent B. Received by (Printed Name) 1Cte of Deliwry D. Is delivery address different frabrfp 17 El Yes If YES, enter delivery address Wm: 03 jn ~ VL'3 3 Service Type 54ertifled mail O Express Mail 0 Registered 0 Return Receipt for Memtmndse 0 Insured Mail 0 C.O.D. 4. Restricted Delivery? (Extra Fee) 0 Yes 2. (r nsNumber 7007 '2560 0001 6044 5201 (lians?er Aron service ?+?9 Ps f=orm 3811, Febnmy 2004 Dorneetic Reburn Receipt 1029*424e4540 208 " 30 AN 8: 58